High Court of Karnataka · Judgments and reasoned final orders
The Pr. Commissioner of Income-Tax, Central & Anr. v. Global Tech Park Pvt. Ltd.
Income Tax Appeal No. 2 of 2026 ·
Section 153A search assessment: addition of Rs. 10 crore based solely on uncorroborated figures scribbled by CFO on loose sheets (explained as loan-eligibility calculations for property acquisition) deleted; loose sheets are not books of account under V.C. Shukla and Sunil Kumar Sharma.
1. FACTS OF THE CASE
Following a search on 01.02.2018, assessment proceedings under section 153A were initiated against Global Tech Park Pvt. Ltd. for AY 2016-17. During the search, certain loose sheets containing figures scribbled by the assessee's Chief Financial Officer (Sri B.V. Vijendra) were found. When confronted, the CFO explained that the scribblings represented hypothetical loan calculations prepared to inflate the valuation of a property (acquired on 28.12.2015 for a registered consideration of Rs. 92 crores, funded by a Rs. 65 crore loan from M/s. Aditya Birla Finance Limited) so as to obtain a higher loan sanction. Although no corroborative material or evidence of cash payment beyond the registered sale deed was found, the AO added Rs. 10 crores on the basis of the loose sheets, which the CIT(A) confirmed on 30.09.2024. By order dated 31.07.2025, the ITAT Bengaluru deleted the Rs. 10 crore addition.
2. DISCUSSION BY THE COURT
Affirming the Tribunal's decision, the Division Bench held that the figures scribbled on the seized loose sheets were completely uncorroborated by any independent evidence indicating that any consideration over and above the registered sale deed price of Rs. 92 crores had actually been paid. Loose sheets do not constitute 'books of account', and uncorroborated scribblings on loose sheets cannot form the sole basis for an assessment addition—a legal position settled by the Supreme Court in Central Bureau of Investigation v. V.C. Shukla & Ors., AIR 1998 SC 1406 and the coordinate Division Bench decision in Deputy Commissioner of Income-Tax v. Sunil Kumar Sharma, [2024] 159 taxmann.com 179 (Karnataka).
3. JUDICIAL DECISION
Holding that in view of the settled law no substantial question of law arose for consideration, the High Court dismissed Income Tax Appeal No. 2 of 2026 at the admission stage.
4. OUTCOME
In favour of the assessee (Global Tech Park Pvt. Ltd.). The Revenue's appeal was dismissed, affirming the deletion of the Rs. 10 crore loose-sheet search addition for AY 2016-17.
5. AKHB REVIEW POINT
AKHB analysis: even where the authorship or ownership of a seized loose sheet is admitted by a company officer (such as a CFO's working sheet for bank-loan financing) and the cheque component matches the registered deed, an addition for alleged on-money cannot survive under V.C. Shukla and Sunil Kumar Sharma unless the Revenue adduces independent corroborative evidence of actual cash payment or receipt.
Source: AKHB analysis based on paragraphs 3, 6-14 / PDF pp. 3-6
Source and verification
Six-page official High Court of Karnataka judgment PDF (2026:KHC:49258-DB); paragraphs 1-14 span PDF pages 1-6.
Original PDF: 6 pages · SHA-256: 80632a75a7782cd9e75814de897e13563a0f32733527498977aa3e060eed2d7b
Supplied source-reviewed note retained; original bytes and identity validation checked in this release. Substantive re-review is not claimed for this record.
Applies sections 132, 153A and 260A of the Income-tax Act, 1961 for AY 2016-17. Income-tax Act, 2025 equivalence is not verified.
Full judgment checked. Follows Central Bureau of Investigation v. V.C. Shukla & Ors., AIR 1998 SC 1406 and Deputy Commissioner of Income-Tax v. Sunil Kumar Sharma, [2024] 159 taxmann.com 179 (Karnataka). Comprehensive subsequent judicial treatment has not been verified.
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